Full opinion text
OPINION KRAUSE, Circuit Judge. This case presents the question whether Abdullah v. American Airlines, Inc., 181 F.3d 368 (3d Cir.1999), in which we held that federal law preempts the field of aviation safety, extends to state law products liability claims. We hold it does not. In light of principles of federalism and the presumption against preemption, Congress must express its clear and manifest intent to preempt an entire field of state law. Here, none of the relevant statutes or regulations signals such an intent. To the contrary, the Federal Aviation Act, the General Aviation Revitalization Act of 1994, and the regulations promulgated by the Federal Aviation Administration reflect that Congress did not intend to preempt aircraft products liability claims in a categorical way. The District Court faithfully sought to apply our precedent, and while it concluded that state products liability claims are preempted by Abdul-lah, it also recognized the question was sufficiently unclear and important to certify its order for interlocutory review. Today, we clarify the scope of Abdullah and hold that neither the Act nor the issuance of a type certificate per se preempts all aircraft design and manufacturing claims. Rather, subject to traditional principles of conflict preemption, including in connection with the specifications expressly set forth in a given type certificate, aircraft products liability cases like Appellant’s may proceed using a state standard of care. For these reasons, we will reverse the District Court’s entry of summary judgment in favor of Appellees and remand for further proceedings. I. Background A. Overview of Federal Aviation Regulation Almost immediately after the airplane became a viable means of transportation, it became clear that certain aspects of aviation, such as air traffic control, required uniform federal oversight. See Air Commerce Act of 1926, ch. 344, 44 Stat. 568. Congress soon thereafter expanded federal control over aviation by enacting the Civil Aeronautics Act of 1938, which created the Civil Aeronautics Authority (“CAA”) to oversee the regulatory aspects of aviation safety and to prescribe “minimum standards governing the design ... of aircraft, aircraft engines, and propellers as may be required in the interest of safety.” Civil Aeronautics Act of 1938, ch. 601, 52 Stat. 973, 1007. The 1938 Act also authorized the CAA to issue so-called “type certificates,” “production certificate^],” and “airworthiness certificate^]” if an airplane or airplane part complied with the relevant safety regulations. Id. at 1007, 1009-10. As the scope of federal involvement in regulating aviation expanded, so too did the number of governmental bodies regulating aviation, and by the 1950s, there had, at one point, been seventy-five different interagency groups with some responsibility in the field. S.Rep. No. 85-1811, at 6 (1958). To resolve this problem, Congress enacted the 1958 Federal Aviation Act, Pub.L. No. 85-726, 72 Stat. 731, to consolidate regulatory authority in a single entity: the Federal Aviation Administration (“FAA”). The Federal Aviation Act adopted verbatim from the Civil Aeronautics Act the statutory framework for the promulgation of minimum standards for design safety and the process for the issuance of certificates that indicated compliance with those regulations. Pursuant to the statutory framework established in the Civil Aeronautics Act and adopted by the Federal Aviation Act, aircraft engine manufacturers must obtain from the FAA (1) a type certificate, which certifies that a new design for an aircraft or aircraft part performs properly and meets the safety standards defined in the aviation regulations, 49 U.S.C. § 44704(a); 14 C.F.R. § 21.31; and (2) a production certificate, which certifies that a duplicate part produced for a particular plane will conform to the design in the type certificate, 49 U.S.C. § 44704(c); 14 C.F.R. § 21.137. Before a new aircraft may legally fly, it must also receive (3) an airworthiness certificate, which certifies that the plane and its component parts conform to its type certificate and are in condition for safe operation. 49 U.S.C. §§ 44704(d), 44711(a)(1). The FAA issues a type certificate when it has determined that a product “is properly designed and manufactured, performs properly, and meets the regulations and minimum standards prescribed under [49 U.S.C. § ] 44701(a).” 49 U.S.C. § 44704(a)(1); see also 14 C.F.R. § 21.21. A type certificate includes the type design, which outlines the detailed specifications, dimensions, and materials used for a given product; the product’s operating limitations; a “certificate data sheet,” which denotes the conditions and limitations necessary to meet airworthiness requirements; and any other conditions or limitations prescribed under FAA regulations. See 14 C.F.R. §§ 21.31, 21.41; FAA, Order 8110.4C, change 5, Type Certification, ch. 3-3(a) (2011). This certification process can be intensive and painstaking; for example, a commercial aircraft manufacturer seeking a new type certificate for a wide-body aircraft might submit 300,000 drawings, 2,000 engineering reports, and 200 other reports in addition to completing approximately 80 ground tests and 1,600 hours of flight tests. See United States v. S.A. Empresa de Viacao Aerea Rio Grandense (Vang Airlines), 467 U.S. 797, 805 n. 7, 104 S.Ct. 2755, 81 L.Ed.2d 660 (1984). A type certificate remains in effect “until surrendered, suspended, revoked, or a termination date is otherwise established by the FAA.” 14 C.F.R. § 21.51. A manufacturer may make both “major” and “minor” changes to a type certificated design, 14 C.F.R. § 21.93, but must obtain the appropriate regulatory approval to do so, which for “major changes” requires the issuance of an amended or supplemental type certificate by the FAA, see 49 U.S.C. § 44704(b); 14 C.F.R. § 21.97; FAA Order 8110.4C, change 1, Type Certification, ch. 4-l(a), 4-2 (2011), and for “minor changes” requires the manufacturer to comply with a pertinent “method acceptable to the FAA,” 14 C.F.R. § 21.95. B. Factual History This case involves alleged manufacturing and design defects in a Textron Lycoming O-320-D2C engine (“the engine”) manufactured in 1969 and installed “factory new” on a Cessna 172N aircraft (“the aircraft”) in 1998. Lycoming holds both a type certificate and production certificate for the engine. The engine in the aircraft was overhauled in 2004 and installed with a MA-4SPA carburetor in accordance with Lycoming’s type-certificated design. David Sikkelee was piloting the aircraft when it crashed shortly after taking off from Transylvania County Airport in Bre-vard, North Carolina in July 2005. Sikkel-ee was killed as a result of serious injuries and burns he suffered in the crash. His wife, Jill Sikkelee, the Plaintiff-Appellant in this case, alleges that the aircraft lost power and crashed as a result of a malfunction or defect in the engine’s carburetor. Specifically, she contends that, “due to the faulty design of the lock tab washers as well as gasket set,” vibrations from the engine loosened screws holding the carburetor’s throttle body to its float bowl. J.A. 643. When properly functioning, a carburetor regulates the mixture of fuel and air that enters the engine’s cylinders. According to Sikkelee, however, the manner by which the throttle body was attached to the float bowl in the Textron Lycoming O-320-D2C engine allowed raw fuel to leak out of the carburetor into the engine and thereby caused the aircraft to crash. C. Procedural History Sikkelee initially filed a wrongful death and survival action in the Middle District of Pennsylvania in 2007 against seventeen defendants, asserting state law claims of strict liability, breach of warranty, negligence, misrepresentation, and concert of action. In 2010, the District Court granted defendants’ motion for judgment on the pleadings, holding that Sikkelee’s state law claims, which were premised on state law standards of care, fell within the preempted “field of air safety” described in Abdul-lah. Sikkelee v. Precision Airmotive Corp., 45 F.Supp.3d 431, 435 (M.D.Pa.2014) (quoting Abdullah, 181 F.3d at 367). Sikkelee subsequently filed an amended complaint, continuing to assert state law claims, but this time incorporating federal standards of care by alleging violations of numerous FAA regulations. Following certain settlements and motion practice, Sikkelee narrowed her claims against Ly-coming to defective design (under theories of both negligence and strict liability) and failure to warn. As the trial date approached, the District Court expressed concern that Sik-kelee’s proposed jury instructions using federal standards of care were “all but completely unable to assist the Court in ... formulating an intelligible statement of applicable law.” Sikkelee, 45 F.Supp.3d at 437 (internal quotation marks omitted) (recounting its position on this point as first expressed in its Memorandum of November 20, 2013). On the one hand, the District Court asserted that, under Abdullah, it was bound to apply some federal standard of care and that compliance with the applicable design and construction regulations was the only identifiable, let alone articu-lable, federal standard. On the other hand, because it determined that the “FAA regulations relating to the design and manufacture of airplanes and airplane component parts were never intended to create federal standards of care,” id. at 437 n. 4 (quoting Pease v. Lycoming Engines, No. 4:10-cv-00843, 2011 WL 6339833, at *22 (M.D.Pa. Dec. 19, 2011) (Conner, J.)) (internal quotation marks omitted), the District Court found it to be “arduous and impractical” to fashion the regulations themselves into such standards, id. (quoting Pease, 2011 WL 6339833, at *23) (internal quotation marks omitted). Faced with this conundrum, the District Court ordered Sikkel-ee to submit additional briefing on the question of the appropriate standard of care and, after review of that briefing, invited Lycoming to file a motion for summary judgment. Id. at 438. In its ruling on that motion, the District Court concluded that the federal standard of care was established in the type certificate itself. Reasoning that the FAA issues a type certificate based on its determination that the manufacturer has complied with the pertinent regulations, the District Court held that the FAA’s issuance of a type certificate for the Textron Lycoming O-320-D2C engine meant that the federal standard of care had been satisfied as a matter of law. Id. at 451-43, 456. The District Court therefore granted Lycom-ing’s summary judgment motion, in part, on that basis. Id. at 456. The District Court denied summary judgment, however, on Sikkelee’s failure to warn claims, which were premised on Lycoming’s alleged violation of 14 C.F.R. § 21.3 for failure to “ ‘report any failure, malfunction, or defect in any product, part, process, or article’ ” that Lycoming manufactured. Id. at 459-60 (quoting 14 C.F.R. § 21.3(a) .(2004)). Recognizing that its grant of partial summary judgment raised novel and complex questions concerning the reach of Ab-dullah and the scope of preemption in the airlines industry, the District Court certified the order for immediate appeal, and we granted interlocutory review. II. Jurisdiction and Standard of Review The District Court had diversity jurisdiction under 28 U.S.C. § 1332(a), and we have jurisdiction under 28 U.S.C. § 1292(b) to review the order certified by the District Court for interlocutory appeal. We review the District Court’s order granting summary judgment de novo. Azur v. Chase Bank, USA, Nat’l Ass’n, 601 F.3d 212, 216 (3d Cir.2010). We also review questions of preemption de novo. Farina v. Nokia Inc., 625 F.3d 97, 115 n. 20 (3d Cir.2010). III. Discussion The doctrine of preemption is a necessary but precarious component of our system of federalism under which the states and the federal government possess concurrent sovereignty, subject to the limitation that federal law is “the supreme Law of the Land ... any Thing in the Constitution or Laws of any State to the Contrary notwithstanding.” U.S. Const, art. VI, cl. 2. Consistent with this principle, Congress has the power to enact legislation that preempts state law. See Arizona v. United States, — U.S.-, 132 S.Ct. 2492, 2500-01, 183 L.Ed.2d 351 (2012). At the same time, with due respect to our constitutional scheme built upon a “compound republic,” with power allocated between “two distinct governments,” The Federalist No. 51, at 323 (James Madison) (Clinton Rossiter ed., 1961); see also U.S. Term Limits, Inc. v. Thornton, 514 U.S. 779, 838, 115 S.Ct. 1842, 131 L.Ed.2d 881 (1995) (Kennedy, J., concurring), there is a strong presumption against preemption in areas of the law that States have traditionally occupied, see Medtronic, Inc. v. Lohr, 518 U.S. 470, 485, 116 S.Ct. 2240, 135 L.Ed.2d 700 (1996); Bruesewitz v. Wyeth, Inc., 561 F.3d 233, 240 (3d Cir.2009) (explaining that, “[w]hen faced with two equally plausible readings of statutory text, [courts] have a duty to accept the reading that disfavors preemption” (internal quotation marks omitted)). For that reason, all preemption cases “start with the assumption that the historic police powers of the States were not to be superseded by the Federal Act unless that was the clear and manifest purpose of Congress.” Wyeth v. Levine, 555 U.S. 555, 565, 129 S.Ct. 1187, 173 L.Ed.2d 51 (2009) (quoting Medtronic, 518 U.S. at 485, 116 S.Ct. 2240) (internal quotation marks omitted). Congressional intent is the “ultimate touchstone” of a preemption analysis. Id. Thus, when confronted with the question of whether state claims are preempted, as we are here, we look to the language, structure, and purpose of the relevant statutory and regulatory scheme to develop a “reasoned understanding of the way in which Congress intended the statute and its surrounding regulatory scheme to affect business, consumers, and the law.” Medtronic, 518 U.S. at 486, 116 S.Ct. 2240; see also Bruesewitz, 561 F.3d at 243-44 (recognizing that divining congressional intent regarding preemption requires considering a law’s “structure and purpose,” underlying “object and policy,” and, where relevant, legislative history (internal quotation marks omitted)). Congress may exert its supremacy by expressly preempting state law, but it may also do so implicitly, which we have recognized in limited circumstances in the doctrine of “field” preemption. See Oneok, Inc. v. Learjet, Inc., — U.S. -, 135 S.Ct. 1591, 1595, 191 L.Ed.2d 511 (2015). For that doctrine to apply, “we must find that federal law leaves no room for state regulation and that Congress had a clear and manifest intent to supersede state law” in that field. Elassaad v. Indep. Air, Inc., 613 F.3d 119, 127 (3d Cir.2010) (quoting Hoik v. Snapple Beverage Gorp., 575 F.3d 329, 336 (3d Cir.2009)) (alteration and internal quotation marks omitted). Where Congress expresses an intent to occupy an entire field, States are foreclosed from adopting any regulation in that area, regardless of whether that action is consistent with federal standards. Oneok, 135 S.Ct. at 1595. In addition to field preemption, federal law may supersede state law through conflict preemption. This occurs when a state law conflicts with federal law such that compliance with both state and federal regulations is impossible, PLIVA, Inc. v. Mensing, 564 U.S. 604, 131 S.Ct. 2567, 2577, 180 L.Ed.2d 580 (2011), or when a challenged state law “stands as an obstacle to the accomplishment and execution of the full purposes and objectives of a federal law,” Williamson v. Mazda Motor of Am., Inc., 562 U.S. 323, 330, 131 S.Ct. 1131, 179 L.Ed.2d 75 (2011) (internal quotation marks omitted). In this case, we are asked to analyze the extent to which federal aviation law preempts state tort law, specifically, products liability claims for defective design. We do not write on a blank slate, but rather, against the backdrop of our decision in Abdullah v. American Airlines, Inc., 181 F.3d 363 (3d Cir.1999). A. Abdullah In Abdullah, we considered the preemptive effect of federal in-flight seatbelt regulations on state law negligence claims for a flight crew’s failure to warn passengers that their flight would encounter severe turbulence. Id. at 365. One of the plane’s crew members had illuminated the fasten seatbelt sign in accordance with the federal regulations, but none of the crew had given the passengers an additional verbal warning of expected turbulence. Id. at 365, 371 & n. 11. When the turbulence hit, the plaintiffs suffered serious injuries. Id. at 365. After the jury found American Airlines liable and awarded the plaintiffs damages, the district court ordered a new trial, holding that the Federal Aviation Act preempted the territorial standards for aviation safety, and thus, that the jury should not have been instructed on a territorial standard of care. Id. at 365-66. We affirmed, explaining that the Federal Aviation Act and federal regulations “establish complete and thorough safety standards for interstate and international air transportation and that these standards are not subject to supplementation by, or variation among, jurisdictions.” Id. at 365. Although we held that federal law preempts state law standards of care in the field of air safety, we also held that it preserves state law remedies. Id. at 364. As such, within the field of air safety, Abdullah instructs that plaintiffs may bring state law causes of action that incorporate federal standards of care. Id. at 365. Our analysis in reaching this conclusión focused on the text and legislative history of the Federal Aviation Act, which was adopted primarily to promote safety in aviation and gave the FAA broad authority to issue safety regulations. Id. at 368-69. We observed that the FAA, in exercising this authority, “has implemented a comprehensive system of rules and regulations, which promotes flight safety by regulating pilot certification, pilot pre-flight duties, pilot flight responsibilities, and flight rules.” Id. at 369 (footnotes omitted). We then reviewed several cases from the Supreme Court and our sister Circuits that had found federal preemption with regard to discrete matters of in-flight operations, including aircraft noise, City of Burbank v. Lockheed Air Terminal Inc., 411 U.S. 624, 633, 93 S.Ct. 1854, 36 L.Ed.2d 547 (1973); pilot regulation, French v. Pan Am Express, Inc., 869 F.2d 1, 6 (1st Cir.1989); and control of flights through navigable airspace, British Airways Bd. v. Port Auth. of N.Y., 558 F.2d 75, 84 (2d Cir.1977). Abdullah, 181 F.3d at 369-71. We paid special heed to 14 C.F.R. § 91.13(a), which proscribes “operating] an aircraft in a careless or reckless manner so as to endanger the life or property of another,” and observed that it provided a catch-all standard of care. Id. at 371. Thus, we concluded that state law standards of care within the “field of aviation safety” were preempted, and we instructed that “a court must refer ... to the overall concept that aircraft may not be operated in a careless or reckless manner” in addition to any specific regulations that may be applicable. Id. Importantly for our purposes, although we stated in broad terms that the Federal Aviation Act preempted the “field of aviation safety,” id., the regulations and decisions we discussed in Abdullah all related to in-air operations, see 14 C.F.R. § 1.1 (“Operate, with respect to aircraft, means use, cause to use or authorize to use aircraft, for the purpose ... of air navigation including the piloting of aircraft....”), and the catch-all standard of care that we held a court “must refer to” applied only to operating, not designing or manufacturing, an aircraft. See 14 C.F.R. §§ 1.1, 91.13. We confirmed the limits of our holding in Abdullah a decade later in Elassaad, 613 F.3d at 121, where we clarified that a flight crew’s oversight of the disembarkation of passengers after an airplane came to a complete stop at its destination was not within the preempted field of aviation safety. By drawing a line between what happens during flight and what happens upon disembarking, we made clear that the field of aviation safety described in Abdullah was limited to in-air operations. Id. at 127-31 (“[T]he [Federal Aviation Act’s] safety provisions appear to be principally concerned with safety in connection with operations associated with flight.” (emphasis added)). Abdullah thus does not govern products liability claims like those at issue here. Indeed, as discussed further below, products liability claims are not subject to the same catch-all standard of care that motivated our field preemption decision in Abdullah; the design regulations governing the issuance of type certificates are not as comprehensive as the regulations governing pilot certification, pilot pre-flight duties, pilot flight responsibilities, and flight rules discussed there; and our post-Abdullah case law cautions us against interpreting the scope of the preempted field too broadly. See Elassaad, 613 F.3d at 131. This conclusion is consistent with other courts that have interpreted Abdullah. For example, the Ninth Circuit, which had previously adopted Abdullah’s conclusion that the Federal Aviation Act preempts state law standards of care in the field of aviation safety, has held that products liability does not fall within that preempted field. Martin ex rel. Heckman v. Midwest Express Holdings, Inc., 555 F.3d 806, 809-11 (9th Cir.2009) (Kozinski, J.). Even the district courts that believed Abdullah compelled them to extend the preempted field to products liability claims, including the District Court in this case, have noted that such a holding was at odds with the federal regulatory scheme governing aviation design and manufacturing. See Sikkelee, 45 F.Supp.3d at 460 (“Yet having endeavored to reconcile Abdullah with the federal regulatory scheme that governs aviation design and manufacturing, this Court — either by way of its own error or that of the precedents it has followed — has reached holdings that it imagines have little to do with Congressional intent.”); see also Pease, 2011 WL 6339833, at *22-23 (stating that Abdullah’s reasoning is over-broad). Having concluded that Abdullah does not control here, we must now determine whether Congress intended the Federal Aviation Act to preempt products liability claims. B. Whether the Presumption Against Preemption Applies Typically, our preemption analysis begins with the presumption that Congress does not preempt areas of law traditionally occupied by the states unless that is its clear and manifest intent. Wyeth, 555 U.S. at 565, 129 S.Ct. 1187. In this case, Appellees argue that the presumption against preemption should not apply in the aviation context given the history of federal involvement in the field. That argument turns, however, on a selective view of history. In general, products liability claims are exemplars of traditional state law causes of action. See Medtronic, 518 U.S. at 491, 116 S.Ct. 2240. Indeed, state law governed the earliest products liability claims in this country. See, e.g., Curtain v. Somerset, 140 Pa. 70, 21 A. 244, 244-45 (1891) (applying Pennsylvania law); Thomas v. Winchester, 6 N.Y. 397, 407-11 (N.Y.1852) (applying New York law); see also Karl N. Llewellyn, On Warranty of Quality, and Society, 36 Colum. L.Rev. 699, 732-44 (1936) (discussing distinctions between the early products liability law of the various .States). More specifically, even aviation torts have been consistently governed by state law. In The Crawford Bros. No. 2, 215 F. 269 (W.D.Wash.1914), which appears to be the earliest tort case involving an aircraft, the court considered the effect of the “legal code of the air” that had been proposed by the International Juridic Committee on Aviation on a salvage claim related to an airplane crash in Puget Sound. Id. at 269-70. The court posited that, if the code had become law, “it would be important to consider its provisions in determining what was reasonable and proper in a cause involving air craft in a common-law action,” much like with rules governing water craft. Id. at 270. The court ultimately dismissed the suit for lack of jurisdiction, as neither the proposed legal code of the air nor maritime law provided for jurisdiction, and instructed that such questions “must be relegated to the common-law courts.” Id. at 271. The decision in Crawford Bros. thus recognized that, absent specific legislation, the common law governed aviation tort claims. Years later, after Congress passed the 1926 Air Commerce Act but before the current type certification regime was imposed, Judge Buffington authored what appears to be this Court’s first decision involving an aviation-related tort claim, Curtiss-Wright Flying Service v. Glose, 66 F.2d 710 (3d Cir.), cert. denied, 290 U.S. 696, 54 S.Ct. 132, 78 L.Ed. 599 (1933). There, a widow brought suit against the Curtiss-Wright Flying Service, an early airline, after her husband was killed in a plane crash as a result of negligent operation. Id. at 711. We analyzed the claims under common law negligence standards, see id. at 712, as no specific legislation or regulation governed those claims. Of course, because that decision preceded Erie Railroad Co. v. Tompkins, 304 U.S. 64, 58 S.Ct. 817, 82 L.Ed. 1188 (1938), our analysis turned on federal, rather than state, common law, but the distinction is not important for our purposes here. Rather, our decision reflects that despite the emergence of federal statutes governing aviation, the common law continued to apply to aviation torts. Since then, in the absence of applicable statutory or regulatory provisions, we have consistently applied state law to tort claims arising from airplane crashes. Only a month before the Federal Aviation Act was enacted, we were faced with a case involving three claims of defective design against an aircraft manufacturer after its plane broke apart in midair. Prashker v. Beech Aircraft Corp., 258 F.2d 602, 603-04 (3d Cir.), cert. denied, 358 U.S. 910, 79 S.Ct. 236, 3 L.Ed.2d 230 (1958). In concluding that the aircraft manufacturer did not negligently design the plane, we did not exclusively rely on the Civil Aeronautics Board’s certification of the relevant design, but rather methodically considered each design defect claim under a common law negligence standard, using the type certificate as but a part of that overall analysis. Id. at 605-07; see also Nw. Airlines v. Glenn L. Martin Co., 224 F.2d 120, 124 (6th Cir.1955), cert. denied, 350 U.S. 937, 76 S.Ct. 308, 100 L.Ed. 818 (1956) (confirming the district court’s decision to leave the question of a manufacturer’s negligent design to the jury for determination of whether the pertinent state standard of ordinary care was met). We have done the same in the years since the Federal Aviation Act replaced the Civil Aeronautics Act, see, e.g., Paoletto v. Beech Aircraft Corp., 464 F.2d 976, 978-82 (3d Cir.1972) (applying a state standard of care to claims for strict liability, negligence, and breach of warranty arising from an airplane crash caused by the collapse of the plane’s right wing); Noel v. United Aircraft Corp., 342 F.2d 232, 236-37 (3d Cir.1964) (rejecting defendant’s argument that approval by the Civil Aeronautics Administration of an airplane’s propeller system was conclusive of compliance with the standard of care), as have other Courts of Appeals, see, e.g., Martin, 555 F.3d at 808; Bennett v. Sw. Airlines Co., 484 F.3d 907, 908 (7th Cir. 2007); McLennan v. Am. Eurocopter Corp., 245 F.3d 403, 426 (5th Cir.2001); In re Air Crash Disaster, 86 F.3d 498, 522-23 (6th Cir.1996); Pub. Health Trust v. Lake Aircraft, Inc., 992 F.2d 291, 293-95 (11th Cir.1993); Cleveland v. Piper Aircraft Corp., 985 F.2d 1438, 1441-47 (10th Cir. 1993); In re N-500L Cases, 691 F.2d 15, 27-28 (1st Cir.1982); Braniff Airways, Inc. v. Curtiss-Wright Corp., 411 F.2d 451, 452-53 (2d Cir.1969); Banko v. Cont’l Motors Corp., 373 F.2d 314, 315-16 (4th Cir.1966). Consistent with the uniform treatment of aviation products liability cases as state law torts, we expressly held in Elassaad that the presumption against preemption applies in the aviation context. See 613 F.3d at 127 (“When considering preemption of an area of traditional state regulation, we begin our analysis by applying a presumption against preemption.... [I]t is appropriate to use a restrained approach in recognizing the preemption of common law torts in the field of aviation.” (quoting Holk, 575 F.3d at 334) (internal quotation marks omitted)); Abdullah, 181 F.3d at 366 (“[We] have addressed claims of preemption with the starting presumption that Congress does not intend to supplant state law.”). Appellees’ attempts to set the presumption aside are therefore unavailing. With this presumption in mind, we must determine whether Congress expressed its clear and manifest intent to preempt aviation products liability claims. We do so by reviewing the text and structure of the Federal Aviation Act, and, to the extent necessary and relevant to this statute, examining subsequent congressional action that sheds light on its intent. See Medtronic, 518 U.S. at 485-86, 116 S.Ct. 2240. We also consider relevant regulations that have been issued pursuant to the valid exercise of the FAA’s delegated authority, which can have the same preemptive effect as federal statutes. See Fellner v. Tri-Union Seafoods, L.L.C., 539 F.3d 237, 243 (3d Cir.2008). C. Indicia of Congressional Intent 1. The Federal Aviation Act As we have explained, although the federal government has overseen certain aspects of aviation; such as air traffic control and pilot certification, since the early days of flight, see Air Commerce Act of 1926, ch. 344, 44 Stat. 568, there was little question when the .Civil Aeronautics Act was adopted in 1938 that common law standards governed tort claims arising from plane crashes, see, e.g., Curtiss-Wright Flying Serv., 66 F.2d at 711-13 (applying the common law standard for negligence). It is therefore significant that the Federal Aviation Act, which succeeded the Civil Aeronautics Act and remains the foundation of federal aviation law today, contains no express preemption provision. In fact, it says only that the FAA may establish “minimum standards” for aviation safety, 49 U.S.C. § 44701— statutory language the Supreme Court has held in other contexts to be insufficient on its own to support a finding of clear and manifest congressional intent of preemption, see Fla. Lime & Avocado Growers, Inc. v. Paul, 373 U.S. 132, 145, 83 S.Ct. 1210, 10 L.Ed.2d 248 (1963); see also Ray v. Atl. Richfield Co., 435 U.S. 151, 168 n. 19, 98 S.Ct. 988, 55 L.Ed.2d 179 (1978); Abdullah, 181 F.3d at 373-74; Cleveland, 985 F.2d at 1445. Further, the Federal Aviation Act contains a “savings clause,” which provides that “[a] remedy under this part is in addition to any other remedies provided by law.” 49 U.S.C. § 40120(c) (emphasis added). The Supreme Court observed that this statutory scheme permits states to retain their traditional regulatory power over aspects of aviation. See Morales v. Trans World Airlines, Inc., 504 U.S. 374, 378-79, 112 S.Ct. 2031, 119 L.Ed.2d 157 (1992) (noting that the Federal Aviation Act’s savings clause permitted the States to regulate intrastate airfares and enforce their own laws against deceptive trade practices prior to the 1978 enactment of the Airline Deregulation Act, which did expressly preempt state laws relating to the rates, routes, or services of an air carrier). While the inclusion of the savings clause “is not inconsistent” with a requirement that courts apply federal standards of care when adjudicating state law claims, Abdullah, 181 F.3d at 374-75, it belies Appellees’ argument that Congress demonstrated a clear and manifest intent to preempt state law products liability claims altogether. Whereas Appellees must show a clear and manifest congressional intent to overcome the presumption against preemption, they instead have mustered scant evidence and, at best, have demonstrated ambiguity. For example, they discuss § 601 of the Federal Aviation Act, which empowers the FAA to promulgate regulations “to promote safety of flight of civil aircraft in air commerce by prescribing ... minimum standards governing the design, materials, workmanship, construction, and performance of aircraft, aircraft engines, and propellers as may be required in the interest of safety.” Federal Aviation Act of 1958, Pub.L. No. 85-726, § 601(a)(1), 72 Stat. 731, 775. Yet, that provision, along with § 603, which provides the statutory framework for the issuance of type certificates, was adopted verbatim from the 1938 Civil Aeronautics Act, id. § 603; see H.R.Rep. No. 85-2360, at 16 (1958), which clearly did not preempt state law products liability claims, see supra, Part III.B. Neither the Federal Aviation Act nor subsequent amendments substantially changed this statutory framework. See Revision of Title 49, United States Code Annotated, “Transportation,” Pub.L. No. 103-272, 108 Stat. 745 (1994); see also H.R.Rep. No. 103-180, at 343-44 (1993) (discussing changes to the statutory provisions governing the issuance of type certificates as words “added for clarity” and “omitted as surplus”). Appellees thus present no evidence from the Federal Aviation Act’s text or extensive legislative history that plausibly suggests Congress intended these same provisions to have a different meaning in the 1958 Act than they had in the 1938 Act. Simply put, if Congress had wanted to change the preemptive effect of the type certification process, it would have done so — or at least given some indication of that intention. It did not. The Federal Aviation Act itself therefore does not signal an intent to preempt state law products liability claims. 2. Federal Aviation Regulations The federal aviation design regulations are likewise devoid of evidence of congressional intent to preempt state law products liability claims. The FAA, in the letter brief it submitted as amicus curiae in this case, takes the position that the Act and these regulations so pervasively occupy the field of design safety that, consistent with Abdullah, they require state tort suits that survive a conflict preemption analysis to proceed under “federal standards of care found in the Federal Aviation Act and its implementing regulations.” Letter Br. of Amicus Curiae Fed. Aviation Admin. 11 (“FAA Ltr. Br.”). We do not defer to an agency’s view that its regulations preempt state law, but we do recognize that agencies are well equipped to understand the technical and complex nature of the subject matter over which they regulate and thus have a “unique understanding of the statutes they administer and an attendant ability to make informed determinations about how state requirements may pose an obstacle to the accomplishment and execution of the full purposes and objectives of Congress.” Wyeth, 555 U.S. at 576-77, 129 S.Ct. 1187 (quoting Hines v. Davidowitz, 312 U.S. 52, 67, 61 S.Ct. 399, 85 L.Ed. 581 (1941)) (internal quotation marks omitted); see also Farina, 625 F.3d at 126. We therefore .consider the FAA’s “explanation of state law’s impact on the federal scheme” governing aircraft design and manufacture, but “[t]he weight we accord [its] explanation ... depends on its thoroughness, consistency, and persuasiveness.” Wyeth, 555 U.S. at 577, 129 S.Ct. 1187 (citing United States v. Mead Corp., 533 U.S. 218, 234-35, 121 S.Ct. 2164, 150 L.Ed.2d 292 (2001); Skidmore v. Swift & Co., 323 U.S. 134, 140, 65 S.Ct. 161, 89 L.Ed. 124 (1944)); Farina, 625 F.3d at 126-27 & n. 27. Specifically, its views as presented in an amicus brief are “ ‘entitled to respect’ only to the extent [they] ha[ve] the ‘power to persuade.’ ” See Gonzales v. Oregon, 546 U.S. 243, 255-56, 126 S.Ct. 904, 163 L.Ed.2d 748 (2006) (quoting Skidmore, 323 U.S. at 140, 65 S.Ct. 161); see also Farina, 625 F.3d at 126-27. Here, three fundamental differences between the regulations at issue in Abdullah and those concerning aircraft design, along with the agency’s inability to specifically identify or articulate the proposed federal standard of care, lead us to disagree with this aspect of the FAA’s submission. First, the regulations governing in-flight ■ operations on their face “prescribe[ ] rules governing the operation of aircraft ... within the United States.” 14 C.F.R. § 91.1(a); see also 14 C.F.R. § 121.1(e) (prescribing rules governing “[e]ach person who is on board an aircraft being operated under this part”). In contrast, the manufacturing and design regulations prescribe “[procedural requirements for issuing and changing — (i) Design approvals; (ii) Production approvals; (iii) Airworthiness certificates; and (iv) Airworthiness approvals” and “[r]ules governing applicants for, and holders of’ such approvals and certificates. 14 C.F.R. § 21.1(a). That is, these regulations do not purport to govern the manufacture and design of aircraft per se or to establish a general standard of care but rather establish procedures for manufacturers to obtain certain approvals and certificates from the FAA, see generally 14 C.F.R. § 21, and in the context of those procedures, to “pre-scriben airworthiness standards for the issue of type certificates,” 14 C.F.R. § 33.1(a) (aircraft engines) (emphasis added); see also 14 C.F.R. §§ 23.1(a), 25.1(a), 27.1(a), 29.1(a), 31.1(a), 35.1(a). Of course, the issuance of a type certificate is a threshold requirement for the lawful manufacture and production of component parts and, at least to that extent, arguably reflects nationwide standards for the manufacture and design of such parts. But the fact that the regulations are framed in terms of standards to acquire FAA approvals and certificates — and not as standards governing manufacture generally— supports the notions that the acquisition of a type certificate is merely a baseline requirement and that, in the manufacturing context, the statutory language indicating that these are “minimum standards,” 49 U.S.C. § 44701, means what it says. Second, the standards that must be met for the issuance of type certificates cannot be said to provide the type of “comprehensive system of rules and regulations” we determined existed in Abdullah to promote in-flight safety “by regulating pilot certification, pilot pre-flight duties, pilot flight responsibilities, and flight rules.” Abdul-lah, 181 F.3d at 369 (footnotes omitted). Rather, many are in the nature of discrete, technical specifications that range from simply requiring that a given component part work properly, e.g., 14 C.F.R. § 33.71(a) (providing that a lubrication system “must function properly in the flight altitudes and atmospheric conditions in which an aircraft is expected to operate”), to prescribing particular specifications for certain aspects (and not even all aspects) of that component part, e.g., 14 C.F.R. § 33.69 (providing that an electric engine ignition system “must have at least two igniters and two separate secondary electric circuits, except that only one igniter is required for fuel burning augmentation systems”). The regulation governing the fuel and induction system at issue in this case, for example, specifies that this part of the engine “must be designed and constructed to supply an appropriate mixture of fuel to the cylinders throughout the complete operating range of the engine under all flight and atmospheric conditions.” 14 C.F.R. § 33.35(a) (emphasis added). As the District Court observed, the highly technical and part-specific nature of these regulations makes them exceedingly difficult to translate into a standard of care that could be applied to a tort claim. Third, the regulations governing inflight operations “suppl[y] a comprehensive standard of care,” Abdullah, 181 F.3d at 371, that could be used to evaluate conduct not specifically prescribed by the regulations, i.e., that a person must not “operate an aircraft in a careless or reckless manner so as to endanger the life or property of another,” 14 C.F.R. § 91.13(a). We recognized in Abdullah that § 91.13(a) sounds in common law tort, making it appropriate and practical to incorporate as a federal standard of care in state law claims concerning in-flight operations and rendering existing state law standards of care duplicative (if not conflicting with them outright). Abdullah, 181 F.3d at 371, 374. Neither the FAA nor Appellees have pointed us to any analogous provision for aircraft manufacture and design, nor have we identified one. We therefore, agree with the District Court that neither the Federal Aviation Act nor the associated FAA regulations “were [ever] intended to create federal standards of care” for manufacturing and design defect claims. Sik-kelee, 45 F.Supp.3d at 437 n. 4 (internal quotation marks omitted) (describing the District Court’s reasoning in its earlier memorandum responding to proposed jury instructions and citing Pease, 201Í WL 6339833, at *22-23). However, the District Court proceeded from that accurate premise to a faulty conclusion (the one urged by Appellees), i.e., that because there is no federal standard of care for these claims in the statute or regulations, the issuance of a type certificate must both establish and satisfy that standard. Not so. In light of the presumption against preemption, absent clear evidence that Congress intended the mere issuance of a type certificate to foreclose all design defect claims, state tort suits using state standards of care may proceed subject only to traditional conflict preemption principles. Besides preserving principles of federalism, this conclusion avoids interpreting the Federal Aviation Act in a way that would have “the perverse effect of granting complete immunity from design defect liability to an entire industry that, in the judgment of Congress, needed more stringent regulation.” Medtronic, 518 U.S. at 487, 116 S.Ct. 2240. Conversely, were we to adopt Appellees’ position, we would be holding, in effect, that the mere issuance of a type certificate exempts designers and manufacturers of defective airplanes from the bulk of liability for both individual and large-scale air catastrophes. While Appel-lees answer that “failure to report defects” claims could still proceed under state law, as the District Court permitted here, even Appellees acknowledge that, at best, only some “percentage of claims that are theoretically available would be léft under [their] interpretation.... ” Oral Arg. at 35:01, 42:54 (argued June 24, 2015). In short, like the manufacturer in Med-tronic, Appellees would have us adopt the position that “because there is no explicit private cause of action against manufacturers contained in the [Act], and no suggestion that the Act created an implied private right of action, Congress would have barred most, if not all, relief for persons injured by defective [aircraft parts].” Medtronic, 518 U.S. at 487, 116 S.Ct. 2240. Like the Supreme Court in Medtronic, however, we find it “to say the least, ‘difficult to believe that Congress would, without comment, remove all means of judicial recourse for those injured by illegal conduct.’ ” Id. (quoting Silkwood v. Kerr-McGee Corp., 464 U.S. 238, 251, 104 S.Ct. 615, 78 L.Ed.2d 443 (1984)). These observations lead us to conclude that the Federal Aviation Act and its implementing regulations do not indicate a clear and manifest congressional intent to preempt state law products liability claims; Congress has not created a federal standard of care for persons injured by defective airplanes; and the type certification process cannot as a categorical matter displace the need for compliance in this context with state standards of care. 3. GARA Our conclusion is solidified by the General Aviation Revitalization Act of 1994 (“GARA”), Pub L. No. 103-298, 108 Stat. 1552 (codified at 49 U.S.C. § 40101 note). In that statute, Congress created a statute of repose that, with certain exceptions, bars suit against an aircraft manufacturer arising from a general aviation accident brought more than eighteen years after the aircraft was delivered or a new part was installed. 49 U.S.C. § 40101 note § 3(3). GARA was adopted to limit the “long tail of liability” imposed on manufacturers of general aviation aircraft. Blazevska v. Raytheon Aircraft Co., 522 F.3d 948, 951 (9th Cir.2008) (quoting Lyon v. Agusta S.P.A., 252 F.3d 1078, 1084 (9th Cir.2001)). By barring products liability suits against manufacturers of these older aircraft parts, GARA necessarily implies that such suits were and are otherwise permitted. Indeed, GARA’s eighteen-year statute of repose would be superfluous if all aviation products liability claims are preempted from day one. Because we must “interpret a statute so as to ‘give effect to every word of a statute wherever possible,’ ” Shalom Pentecostal Church v. Acting Sec’y U.S. Dep’t of Homeland Sec., 783 F.3d 156, 165 (3d Cir.2015) (quoting Leocal v. Ashcroft, 543 U.S. 1, 12, 125 S.Ct. 377, 160 L.Ed.2d 271 (2004)), GARA reinforces what is now apparent: Federal law does not preempt state design defect claims. Rather, Congress left state law remedies in place when it enacted GARA in 1994, just as it did when it enacted the Civil Aeronautics Act in 1938 and the Federal Aviation Act in 1958. Appellees argue that GARA would not be entirely superfluous because general aviation manufacturers would “remain subject to state tort remedies for actual violations of federal aviation safety standards,” Appellee’s Br. 51, such as the failure to disclose defects discovered after a type certificate has been issued or the failure to comply with an airworthiness directive, Oral Arg. at 35:20, 37:00. Those kinds of claims, however, are already expressly exempted in § 2(b)(1) from GARA’s statute of repose. In sum, if GARA and its § 2(b)(1) carveout are to serve their stated purpose, the state law claims to which GARA’s statute of repose applies must not be preempted. Our interpretation of the Federal Aviation Act is only bolstered by GARA’s legislative history. We are mindful, of course, that “the authoritative statement is the statutory text, not the legislative history or any other extrinsic material,” as legislative history can be “murky, ambiguous, and contradictory.” Exxon Mobil Corp. v. Allapattah Servs., Inc., 545 U.S. 546, 568, 125 S.Ct. 2611, 162 L.Ed.2d 502 (2005). Here, however, the legislative history is none of those things. GARA’s legislative history states explicitly what is implied by the statutory text: Aviation products liability claims are governed by state law. See H.R.Rep. No. 103-525, pt. 2, at 3-7 (1994). The House Report begins by stating that “[t]he liability of general aviation aircraft manufacturers is governed by tort law” that “is ultimately grounded in the experiences of the legal system and values of the citizens of a particular State.” Id. at 3-4. In enacting GARA, Congress “voted to permit, in this exceptional instance, a very limited Federal preemption of State law,” that is, only where GARA’s statute of repose has run are state law claims preempted. Id. at 4-7. “[I]n cases where the statute of repose has not expired, State law will continue to govern fully, unfettered by Federal interference.” Id. at 7. Appellees attempt to discount GARA’s significance, arguing that the views of Congress in 1994 “form a hazardous basis for inferring the intent” of the 1958 Congress that enacted the Federal Aviation Act. Ap-pellee’s Br. 41 (quoting United States v. Price, 361 U.S. 304, 313, 80 S.Ct. 326, 4 L.Ed.2d 334 (1960)). It is true that “the weight given subsequent legislation and whether it constitutes a clarification or a repeal is a context- and fact-dependent inquiry,” Bd. of Trs. of IBT Local 863 Pension Fund v. C & S Wholesale Grocers, Inc., 802 F.3d 534, 546 (3d Cir.2015), but there are circumstances where its consideration is appropriate. Indeed, the Supreme Court relied on precisely this type of analysis in determining congressional intent in the preemption context in Silkwood v. Kerr-McGee Corp., 464 U.S. 238, 104 S.Ct. 615, 78 L.Ed.2d 443 (1984). There, the Court considered the question of whether state law actions for punitive damages were subject to field preemption under the Atomic Energy Act of 1954, 42 U.S.C. §§ 2011-2284. Silkwood, 464 U.S. at 241, 104 S.Ct. 615. The Atomic Energy Act itself was silent on the preemption of state tort claims, but, when it was subsequently amended by the Price-Anderson Act, Pub.L. No. 85-256, 71 Stat. 576 (1957), the accompanying Joint Committee Report reflected an assumption that state law would apply in the absence of subsequent legislative action. Id. at 251-54, 104 S.Ct. 615. The Supreme Court found this legislative history to be persuasive in concluding that Congress did not intend to foreclose state remedies for those injured by nuclear accidents by way of field preemption. Id. at 256,104 S.Ct. 615. More recently, in Texas Department of Housing & Community Affairs v. Inclusive Communities Project, Inc., — U.S. -, 135 S.Ct. 2507, 192 L.Ed.2d 514 (2015), the Supreme Court held that disparate impact claims were cognizable under the 1968 Fair Housing Act (“FHA”), relying in part on the “crucial[ly] importan[t]” fact that Congress had adopted amendments to the Act in 1988 that assumed the existence of such claims. Id. at 2519-20. Because the amendments would make sense only if disparate impact liability existed under the FHA, the Court reasoned that the most logical conclusion was that Congress presupposed the existence of disparate impact claims under the FHA as it had been enacted in 1968. Id. at 2520-21. Consistent with the Supreme Court’s approach and our recent guidance in Board of Trustees of IBT Local 863 Pension Fund, we may pay heed to the significance of subsequent legislation when it is apparent from the facts and context that it bears directly on Congress’s own understanding and intent. Here, the Federal Aviation Act itself neither states nor implies an intent to preempt state law products liability claims, and GARA confirms that Congress understood and intended that Act to preserve such claims. Thus, despite Ap-pellees’ exhortations, we cannot infer a clear and manifest congressional purpose to preempt these claims where the indicia of congressional intent, including in this case the assumptions underlying subsequent legislation, point overwhelmingly the other way. D. Relevant Preemption Precedent We turn next to Appellees’ contention that the Supreme Court’s preemption jurisprudence compels us to find that federal law occupies the entire field of aircraft design and manufacture and that the issuance of a type certificate conclusively demonstrates compliance with the corresponding federal standard of care. Appellees argue that: (1) the Court has accorded broad field preemption to analogous statutory regimes governing oil tankers and locomotives; (2) the Court has given broad preemptive effect to analogous premarket approval processes in the medical device context; and (3) other Courts of Appeals have recognized preemption of the field of aviation safety. For its part, the FAA argues that the mere issuance of a type certificate does not preempt all design defect claims concerning the certificated part but that specifications expressly embodied in a type certificate may, in a given case, preempt such claims under traditional conflict preemption principles. We address Appellees’ arguments below and conclude that the case law of the Supreme Court and our sister Circuits supports the application of traditional conflict preemption principles but not preemption of the entire field of aviation design and manufacture. 1. Field Preemption in Analogous Statutory Regimes Although they acknowledge that the Supreme Court has not addressed whether the Federal Aviation Act preempts the field of aviation design and manufacture, Appellees argue on the basis of other Supreme Court precedent that we should affirm the reasoning of the District Court. First, Appellees point to the Supreme Court’s observation in City of Burbank, 411 U.S. at 639, 93 S.Ct. 1854, that the Federal Aviation Act “requires a uniform and exclusive system of federal regulation if the congressional objectives underlying [it] are to be fulfilled” as evidence that the Supreme Court has concluded the FAA occupies the entire field of aviation safety. That begs the question, however, of the scope of the field in question. In City of Burbank, the Court held only that Congress had preempted the field of aircraft noise regulation. Id. at 633, 638-40, 93 S.Ct. 1854. Even in interpreting the express preemption clause of the Airline Deregulation Act, the Court has taken a cautious approach, holding that plaintiffs’ claims under state consumer protection statutes are preempted but that related state law claims for breach of contract are not. See Am. Airlines, Inc. v. Wolens, 513 U.S. 219, 223, 227-33, 115 S.Ct. 817, 130 L.Ed.2d 715 (1995); Morales, 504 U.S. at 391, 112 S.Ct. 2031. The Supreme Court also has observed in dicta that state tort law “plainly applies]” to aviation tort cases and that Congress would need to enact legislation “[i]f federal uniformity is the desired goal with respect to claims arising from aviation accidents.” Exec. Jet Aviation, Inc. v. City of Cleveland, 409 U.S. 249, 273-74, 93 S.Ct. 493, 34 L.Ed.2d 454 (1972). The Court’s few pronouncements in the area of aviation preemption, in other words, offer little support for the broad field preemption Appellees seek. Appellees next compare aircraft to oil tankers and locomotives, urging that the broad scope of field preemption recognized by the Supreme Court in those industries should extend as well to aircraft design defect claims. As Appellees point out, the Supreme Court has found field preemption of oil tanker design, operation, and seaworthiness under Title II of the Ports and Waterways Safety Act and concluded state regulations that impose additional crew training requirements and mandate standard safety features on certain boats fall within this preempted field. United States v. Locke, 529 U.S. 89, 109-14, 120 S.Ct. 1135, 146 L.Ed.2d 69 (2000); Ray, 435 U.S. at 158-68, 98 S.Ct. 988. Appellees also refer to decisions that have found field preemption of design defect claims in the railroad context, see Kurns v. R.R. Friction Prods. Corp., — U.S.-, 132 S.Ct. 1261, 1267-68, — L.Ed.2d - (2012); Del. & Hudson Ry. Co. v. Knoedler Mfrs., Inc., 781 F.3d 656, 661-62 (3d Cir.2015). We do not find either of these analogies apt. As to tankers, the Supreme Court subsequently distinguished Ray and Locke on the grounds that both cases invalidated state regulations that created positive obligations, and neither of those cases “purported to pre-empt possible common law claims,” Sprietsma v. Mercury Marine, 537 U.S. 51, 69, 123 S.Ct. 518, 154 L.Ed.2d 466 (2002), such as the aviation tort claims at issue here. As to locomotives, the Supreme Court and our own Court were bound to find such design defect claims preempted by the Supreme Court’s ninety-year-old precedent in Napier v. Atlantic Coast Line Railway Co., 272 U.S. 605, 47 S.Ct. 207, 71 L.Ed. 432 (1926), which held that the Locomotive Inspection Act preempts “the field of regulating locomotive equipment used on a highway of interstate commerce,” including “the design, the construction, and the material of every part of the locomotive and tender and of all appurtenances.” Id. at 607, 611, 47 S.Ct. 207. Far more apropos in the transportation industry is the Supreme Court’s conflict preemption approach in the context of automobiles and boats, for just as the Federal Aviation Act directs the FAA to “pre-scrib[e] minimum standards required in the interest of safety for appliances and for the design, material, construction, quality of work, and performance of aircraft, aircraft engines, and propellers,” 49 U.S.C. § 44701(a)(1), the National Traffic and Motor Safety Act of 1966 (“NTMSA”) empowers the National Highway Traffic Safety Administration to “prescribe motor vehicle safety standards for motor vehicles and motor vehicle equipment,” 49 U.S.C. § 30101(1), and the Federal Boat Safety Act of 1971 (“FBSA”) authorizes the Secretary of Transportation to issue regulations “establishing minimum safety standards for recreational vessels and associated equipment,” 46 U.S.C. § 4302(a)(1). Moreover, like the Federal Aviation Act, the NTMSA and FBSA both contain savings clauses. 49 U.S.C. § 30103(e); 46 U.S.C. § 4311(g). In assessing implied preemption under these statutory schemes, the Supreme Court has found that the statutory language and applicable regulations support not field preemption, but rather a traditional conflict preemption analysis. In the automobile context, for example, the Court held that a federal regulation governing air bag usage implicated a significant federal regulatory objective — maintaining manufacturer choice — and therefore preempted a state law tort claim, Geier v. Am. Honda Motor Co., 529 U.S. 861, 875, 886, 120 S.Ct. 1913, 146 L.Ed.2d 914 (2000), while another regulation governing seatbelt usage did not reflect a similarly significant federal objective and thus did not preempt state law claims, Williamson, 562 U.S. at 336, 131 S.Ct. 1131. Similarly, in Sprietsma, the Court held that the Federal Boat Safety Act did not preempt the field of “state common law relating to boat manufacture,” but nonetheless applied a conflict preemption analysis to determine whether petitioner’s tort law claims were preempted by the Federal Boat Safety Act (“FBSA”) or the Coast Guard’s decision not to promulgate a regulation requiring propeller guards on motorboats. 537 U.S. at 60-70,123 S.Ct. 518. The Court held that the Coast Guard’s decision not to regulate did not preclude “a tort verdict premised on a jury’s finding that some type of propeller guard should have been installed on this particular kind of boat equipped with respondent’s particular type of motor” because the Coast Guard’s decision “does not convey an ‘authoritative’ message of a federal policy against propeller guards.” Id. at 67, 123 S.Ct. 518. In sum, the Supreme Court’s preemption cases in the transportation context support that aircraft design and manufacture claims are not field preempted, but remain subject to principles of conflict preemption. 2. Type Certification As Support for Field Preemption Appellees also assert that because type certificates represent the FAA’s determination that a design meets federal safety standards, allowing juries to impose tort liability notwithstanding the presence of a type certificate would infringe upon the field of aviation safety as defined in Ab-dullah and would fatally undermine uniformity in the federal regulatory regime. Appellees’ Br. 44-45 (quoting City of Burbank, 411 U.S. at 639, 93 S.Ct. 1854). In support of this argument, Appellees rely on Riegel v. Medtronic, Inc., 552 U.S. 312, 128 S.Ct. 999, 169 L.Ed.2d 892 (2008), in which state tort claims were deemed preempted by an express preemption clause where the plaintiff challenged the safety of a medical device that had received preapproval from the Food and Drug Administration. Id. at 330, 128 S.Ct. 999. Although there is no express preemption clause here, Appellees posit that the FAA’s type certification process should be accorded a similar field preemptive effect. The FAA, on the other hand, argues that type certification is relevant only to an analysis under “ordinary conflict preemption principles.” FAA Ltr. Br. 2. Thus, according to the FAA, “[i]t is ... only where compliance with both the type certificate and the claims made in th